Analysis of Notifications and Circulars for Week Ending 27th September 2026

Summary: The week from 21st to 27th September 2026 witnessed important regulatory and judicial developments across Income Tax, GST, Customs, SEBI, IBBI and RBI. Income Tax amendments modified TDS rules relating to transfer of immovable property by non-residents. Several GST Advance Rulings dealt with employee canteen recoveries, agricultural warehousing, digital cinema equipment leasing, electricity recoveries, paper classification, aquaculture gear boxes, market fee collection, semen sorting services, land survey charges, psyllium seeds, mining royalty and rubberised cork sheets. Customs developments included revision of Basic Customs Duty rates, appointment of common adjudicating authorities, addition of customs ports, anti-dumping and countervailing duties, clarification on CAROTAR and Rules of Origin, additional export declaration requirements for textile products and adjudication of Section 28AAA cases involving DGFT scrips. SEBI announced key decisions from its Board meeting. IBBI amended the Liquidation Process Regulations and issued circulars concerning delayed filing fees, PGIRP forms and interim moratorium for personal guarantors. RBI issued amendments relating to FEMA export proceeds, market-risk capital requirements, UAPA compliance, Maldives Line of Credit, InvIT/REIT valuation and novation of OTC derivatives. The week also included significant NCLAT and Supreme Court decisions concerning Section 10A of IBC, arbitration proceedings and tender eligibility.

Notifications & Circulars issued during week (21st – 27th Sep 2026)

(Income Tax, GST, Central Excise, Custom Duty, DGFT, SEBI, MCA, IBBI, RBI)
(Click the Link for Notification/ Circular as issued)

A. Income Tax

Amendments in TDS Rules for Non-Resident Immovable Property Transfers: The amendments modify rules 215, 218 and 219 and Appendix III in relation to tax deduction at source under section 393(2) of Income-tax Act. These remove the mandatory requirement for resident individuals or HUFs to obtain a Tax Deduction Account Number (TAN) when deducting TDS on immovable property purchases from non-residents. Form No 141 is amended to now incorporate section 393(2) transactions and a new Schedule E for reporting TDS on consideration for transfer of immovable property.

(Link: Income Tax Notification 121/2026 Dated 22/09/2026)

B. GST

AAR, Employee Canteen Recovery not Supply, ITC Allowed to Employer: Case of Torrent Pharmaceuticals Ltd, AAR Gujarat Ruling Dated 25^th September 2026. AAR ruled that GST is not applicable on the nominal amounts recovered from employees for subsidized canteen services. The Input Tax Credit (ITC) is available where providing a canteen is a statutory obligation.

AAR, Godown Rent for hiring godown for Agricultural Warehousing attracts 18% GST: Case of Gujarat State Warehousing Corporation, AAR Gujarat Ruling Dated 21^st September 2026. AAR ruled that rent paid for hiring godown is subject to an 18% GST rate, even when used exclusively for storing tax-exempt agricultural produce. The entry 54(e) of notification 12/2017 (Rate) exempts agricultural storage, but does not exempt the underlying property rent. The ITC is not available because output agricultural warehousing services are exempt.

AAR, Digital Cinema Equipment Leasing Is Mixed Supply taxable at Highest GST: Case of UFO Moviez India Limited, AAR Telangana Ruling Dated 18^th September 2026. The core issue relates to classification and tax rate applicable on the leasing and supply of digital cinema theatre equipment bundled with various services or components. AAR ruled that the transaction is treated as a mixed supply under the GST Act, (does not qualify as a naturally bundled composite supply) and attracts the highest rate among the supplies involved.

AAR, Electricity Charges recovered at actuals by Maintenance Entities excluded from GST Value: Case of DH Maintenance Limited, AAR West Bengal Ruling Dated 1^st September 2026. AAR held that electricity charges recovered by a premises-maintenance service provider from commercial unit holders at actual cost, without any mark-up, may be excluded from the taxable value by applying the “pure agent” principle.

AAR, Paper for Exercise Books under HSN 4802 qualifies for GST Exemption: Case of Radha Paper Agencies, AAR West Bengal Ruling Dated 1^st September 2026. AAR ruled that the supply of uncoated paper (HSN 4802) exclusively for manufacturing educational notebooks is exempt from GST. While the same paper used for non-educational notebooks, office work, or commercial printing attracts 18% GST rate.

AAR, Ruled Paper remains under Heading 4802, NIL GST depends on Actual End-Use: Case of Mangalam Kallani HUF, AAR West Bengal Ruling Dated 1^st September 2026. AAR ruled that Cut/ruled loose sheets remain under Heading 4802 rather than shifting to stationery Heading 4820. The End-use NIL exemptions do not extend to intermediate suppliers, as supply chain tiers are treated as independent, end-use applies only at final consumption.

AAR, Aquaculture Gear Boxes taxable at 18% GST under HSN 84834000: Case of BAS-J Industries, AAR Tamil Nadu Ruling Dated 18^th August 2026. The AAR noted that gearboxes are general-purpose transmission elements and do not qualify as parts exclusively designed for agricultural or horticultural machinery under the lower tax bracket. It ruled that aquaculture aerator gearboxes manufactured by the fall under HSN 84834000 and are subject to 18% GST rate.

AAR, Market Fee Collection by Town Panchayat not GST Supply: Case of Muthur Town Panchayat, AAR Tamil Nadu Ruling Dated 10^th August 2026. AAR ruled that the leasing of the right to collect weekly market entry fees by Muthur Town Panchayat is not a supply of goods or services and is exempt from GST.

AAR, Semen Sorting Services classified under SAC 998349, taxable at 18% GST: Case of Jiva Sciences Private Limited, AAR Tamil Nadu Ruling Dated 6^th August 2026. The applicant argued that its service should be classified under SAC 9986 (Support services to agriculture, forestry, fishing, and animal husbandry) and therefore be exempt from GST, similar to the exemption granted to raw semen dose. AAR ruled that semen sorting services utilizing specialized technology do not qualify for a GST exemption. It classified these activities under SAC 998349 (Other technical & scientific services nowhere else classified), making them taxable at a 18% GST rate.

(Link: AAR Tamil Nadu Ruling Dated 06/08/2026)

AAR, ITC denied on Land Survey Charges for Golf Course Afforestation Land: Case of Ootacamund Gymkhana Club, AAR Tamil Nadu Ruling Dated 4^th August 2026. The core issue is whether ITC is admissible on GST paid to a land surveyor for measuring forest land used for the golf course and identifying alternate land required for afforestation compliance. AAR denied ITC, holding that Section 17(5)(h) of the CGST Act applies because the alternate land was surrendered to the Forest Department and its cost was written off in the club’s financial books.

(Link: AAR Tamil Nadu Ruling Dated 04/08/2026)

AAR, Psyllium Seeds Not Fresh, attracts 5% GST Rate: Case of Santosh Devi Daga, AAR Rajasthan Ruling Dated 4^th August 2026. The firm trades Psyllium Seeds (Isabgol) directly from farmers without undergoing any manufacturing, processing, or chemical transformation, through an Agricultural Produce Market Committee (APMC). The applicant argued that the seeds should be exempt as “fresh or chilled” goods as agricultural items. AAR observed that the traded seeds were dried and not in their fresh state. It ruled that they must be taxed at a 5% GST rate.

AAR, GST Payable on Mining Royalty by Short-Term Permit Holder: Case of Pinkcity Developers, AAR Rajasthan Ruling Dated 4^th August 2026. AAR held that royalty paid by short-term mineral permit holders is taxable at 18% under the Reverse Charge Mechanism (RCM).

AAR, Rubberised Cork Sheets are classified Under HSN 45041010, attracts 5% GST Rate: Case of Balasaria Agencies Pvt Ltd, AAR Rajasthan Ruling Dated 4^th August 2026. The issue was whether industrial sheets made from cork granules mixed with polymer/rubber (containing 30.99% cork and 42.47% polymer) fall under Chapter 45 (Cork articles at 5% GST) or Chapter 40 (Rubber articles at 18% GST). AAR ruled that rubberised and agglomerated cork sheets manufactured by the party are classified under HSN 4504 with a 5% GST rate.

(Link: AAR Rajasthan Ruling Dated 04/08/2026)

C. Central Excise

No Notifications/ Circulars during the week.

D. Custom Duty

Revision in Basic Customs Duty (BCD) Rates: The notification amends principal notification 45/2025, dated 24^th October 2025, and revises the Basic Customs Duty (BCD) rates on edible oils.

(Link: Customs Notification 31/2026 (T) Dated 23/09/2026)

Common Adjudicating Authority appointed for R&M India Customs SCN: The Principal Commissioner/Commissioner of Customs, Airport & Air Cargo Commissionerate, Bengaluru has been appointed as the common adjudicating authority, for specified show cause notices issued to R&M India Pvt Ltd, Bengaluru.

(Link: Customs Notification 79/2026 (NT) Dated 24/09/2026)

Common Adjudicating Authority appointed for Tirupati Udyog Limited Customs SCN:

The Principal Commissioner or Commissioner of Customs, Hyderabad, GST Bhavan, Lal Bahadur Stadium Road, Basheerbagh, Hyderabad, is specified as the common adjudicating authority, for adjudication of the specified show cause notice concerning Tirupati Udyog Limited, Kotur.

(Link: Customs Notification 78/2026 (NT) Dated 23/09/2026)

Common Adjudicating Authority appointed for Meenakshi Trading Corporation Customs SCN: The Principal Commissioner or Commissioner of Customs (Import-I), Mumbai Customs Zone-I, New Custom House, Ballard Estate, Mumbai, is specified as the common adjudicating authority, for adjudication of the specified show cause notices concerning Meenakshi Trading Corporation and others.

(Link: Customs Notification 77/2026 (NT) Dated 23/09/2026)

Addition of Campbell Bay and Car Nicobar for Import Export Handling

Addition of Campbell Bay and Car Nicobar for Import Export Handling: The notification adds Campbell Bay and Car Nicobar as customs ports under Section 7(1)(a) of the Customs Act, for the unloading of imported goods and the loading of export goods (or any specific class of such goods), in the Union Territory of Andaman and Nicobar Islands.

(Link: Customs Notification 76/2026 (NT) Dated 23/09/2026)

Anti-Dumping Duty on Bangladesh and Nepal Jute Products: The notification amends earlier notification 33/2022 (ADD), dated 30^th December 2022, relating to anti-dumping duty on specified jute products originating in or exported from Bangladesh and Nepal. It re-quantifies the anti-dumping duty for the remaining period of its imposition, and substitutes the existing table with producer-specific duty rates for Jute Yarn/Twine, Hessian Fabric and Jute Sacking Bags.

(Link: Customs Notification 24/2026 (ADD) Dated 24/09/2026)

Anti-Dumping Duty on Decor Paper Extended: The notification amends earlier notification 77/2021 (ADD) dated 27^th December 2021, and extends the levy of anti-dumping duty on imports of Decor Paper, originating in or exported from China, up to and inclusive of 26^th March 2027.

(Link: Customs Notification 23/2026 (ADD) Dated 22/09/2026)

Countervailing Duty Imposed on Calcium Carbonate Filler Masterbatch from Vietnam: Countervailing Duty has been Imposed on imports of Calcium Carbonate Filler Masterbatch originating in or exported from Vietnam, and imported into India. It shall be effective for a period of five years.

(Link: Customs Notification 04/2026 (CVD) Dated 23/09/2026)

Application of Section 28DA of Customs and CAROTAR consistent with the Rules of Origin under Trade Agreements: The Circular states that where CAROTAR conflicts with the Rules of Origin under a Trade Agreement, the latter shall prevail. For preferential claims under the India–UK CETA, a valid Origin Declaration completed by the UK exporter or producer constitutes proof of origin and Form-I is not required with the Bill of Entry or as a precondition for preferential tariff treatment. Relevant Form-I information may be sought only where the Bill of Entry is interdicted by the National Risk Management System for origin-related checks and the proper officer has reason to believe that origin criteria have not been met.

(Link: Customs Circular 43/2026 Dated 24/09/2026)

Mandatory additional qualifiers in export declarations in respect of certain Textile Products: The circular mandates additional qualifiers and identifiers in export declarations for specific textile products effective from 1^st November 2026. Certain woven and knitted fabrics used for Fire/Flame Retardant (FR) textile products fall under Chapters 52, 55, and 60 of the Customs Tariff. These tariff codes also cover non-FR textile products, making it hard to electronically distinguish between FR and non-FR variants. The additional qualifiers shall help accurately identify products, assisting with schemes like the Production Linked Incentive (PLI) and data clarity.

(Link: Customs Circular 42/2026 Dated 24/09/2026)

Clarifications on Adjudication of Section 28AAA Customs SCNs involving DGFT Scrips: The instructions clarify the procedure for adjudicating Show Cause Notices, where adjudication has remained pending for want of cancellation of the relevant instrument or scrip by DGFT. Where Customs/DRI alleges that an instrument or scrip was fraudulently obtained because of misdeclaration in the Shipping Bill, including misclassification, overvaluation or other incorrect declarations, Customs must first investigate and adjudicate the matter under the Customs Act and, where warranted, consequentially amend the Shipping Bill. Where the dispute concerns policy interpretation, eligibility, entitlement or another matter within DGFT’s domain, the matter must first be referred to DGFT, whose view on validity and entitlement shall prevail for those policy-related issues.

(Link: Customs Instructions 17/2026 Dated 21/09/2026)

E. Directorate General of Foreign Trade (DGFT)

No Notifications/ Circulars during the week.

F. Securities and Exchange Board of India (SEBI)

Key decisions taken in the SEBI Board Meeting

Key decisions taken in the SEBI Board Meeting: The Board approved new SEBI (Portfolio Managers) Regulations, 2026, including investment in IPOs, certain unlisted debt and foreign securities, PRIM for mutual fund investments, Independent Fund Managers and simplified compliance requirements. The Board also approved SEBI (Settlement of Administrative and Civil Proceedings) Regulations, 2026, introducing revised settlement terms, a new computation formula, settlement notices before show-cause notices, longer filing periods, fast-track settlement and a one-time settlement opportunity. Other decisions include a Common Advertisement Code, wider FPI participation in commodity derivatives, Depository Receipts on REIT and InvIT units.

(Link: SEBI Press Release dated 24/09/2026)

G. Ministry of Corporate Affairs (MCA)

No Notifications/ Circulars during the week.

H. Insolvency and Bankruptcy Board of India (IBBI)

Amendments to IBBI Liquidation Process Regulations: As per the amended provisions, a liquidator may modify an entry in the list of stakeholders when additional information comes to his notice which warrants such modification. Where such modification is made, the liquidator is required to intimate the Adjudicating Authority regarding the modification within thirty days of making it.

(Link: IBBI Notification Dated 22/09/2026)

Commencement of levy of fee for delayed filing of Forms under Regulation 47B of Liquidation Process Regulations: The circular provides that each Form which is due on or before 30^th September 2026 and is submitted after its due date, whether by correction, up-dation or otherwise, shall be accompanied by a fee of Rs 500 plus GST, per month for the period of delayed filing. Regulation 47B mandates electronic filing of prescribed, stage-wise compliance forms by liquidator on the electronic platform of IBBI.

(Link: IBBI Circular Dated 24/09/2026)

Personal Guarantors Insolvency Resolution Process (PGIRP) Forms filing Deadline Extended: The circular further extends the time for filing electronic forms PGIRP-1 to PGIRP-6 to 31^st December 2026 (Earlier 30^th September 2026). These forms are used to monitor insolvency resolution processes concerning personal guarantors to corporate debtors.

(Link: IBBI Circular Dated 24/09/2026)

Clarifications on Cessation of Interim Moratorium in respect of Personal Guarantors to Corporate Debtors: The circular has drawn attention to judgments of the Bombay High Court and Delhi High Court concerning cessation of the interim moratorium applicable to personal guarantors to corporate debtors. It refers to the IBC (Amendment) Act, 2026, which inserted section 96(4) and 124, with effect from 26^th May 2026. It has been clarified that the interim moratorium under section 96 and correspondingly section 124, in respect of a personal guarantor to a corporate debtor, ceased to operate with effect from 26^th May 2026 in respect of applications pending before the Adjudicating Authority as on that date.

(Link: IBBI Circular Dated 21/09/2026)

NCLAT, Section 10A bars CIRP as Default Dates fell in Protected Period: Case of Siddharth Satish Katariya vs Central Bank of India Limited, NCLAT Delhi Judgement Dated 1^st September 2026. Section 10A provides that if a default arises within the protected period i.e. 25^th March 2020, to 24^th March 2021, no CIRP application can ever be filed for that specific default. The appellate tribunal ruled that the default dates fell within the permanently protected period thus quashed the insolvency proceedings.

I. Reserve Bank of India (RBI)

Amendments to FEMA Export and Import of Goods and Services Regulations: The main change is a reduction in the period for realisation and repatriation of export proceeds. The period prescribed under Regulation 5(1) has been reduced from 15 months to 9 months, while the special period prescribed in the first proviso has been reduced from 18 (eighteen) months to 12 (twelve) months. It also introduces a new Regulation 20, under which Authorised Dealer (AD) Banks are empowered to handle certain pre- 1^st October 2026, export, import and merchanting trade transactions which, under the earlier regulatory framework, would have required RBI approval.

(Link: FinMin FEMA Notification Dated 22/09/2026)

RBI Commercial Banks Minimum Capital Requirements for Market Risk Directions 2026: These directions shall apply to commercial banks, excluding Small Finance Banks, Payments Banks and Local Area Banks. Banks must compute market risk capital requirements continuously and maintain capital at both consolidated and standalone levels. The framework permits qualifying structural foreign exchange positions to be excluded from Net Open Position subject to specified conditions. For computation of market-risk RWAs, banks must use the simplified standardised approach, with risk-weighted assets determined by multiplying prescribed capital requirements by 12.5. The Directions also prescribe Basel III Pillar 3 disclosures, including annual qualitative market-risk disclosures and semi-annual quantitative disclosures.

(Link: RBI Directions 472/2026 Dated 21/09/2026, Press Release)

Updates on terrorist organisations under UAPA Act: MEA has informed about declaring Shahzad Bhatti Network (SBN) as a ‘Terrorist Organisation’ and listing it in the First Schedule to Unlawful Activities (Prevention) Act. Regulated Entities (REs) are advised to take note for necessary compliance in terms of Master Directions on KYC.

(Link: RBI Circular 270/2026 Dated 24/09/2026)

Exim Bank Line of Credit for Maldives Projects: The Govt of India has approved Export-Import Bank Line of Credit of Rs 4,850 crores for financing various developmental projects in Maldives. Eligible exports of goods and services from India will be permitted subject to their eligibility under Foreign Trade Policy and their financing being agreed by Exim Bank. At least 75% of the applicable contract price must comprise goods, works and services supplied by the seller from India, while the remaining 25% may be procured from outside India for the eligible contract.

(Link: RBI Circular 269/2026 Dated 23/09/2026)

Amendments to RBI All India Financial Institutions Classification, Valuation, and Operation of Investment Portfolio Directions: The amendments provide clarity and uniform practices for valuation of units of Infrastructure Investment Trusts (InvITs) and Real Estate Investment Trusts (REITs). It prescribes that quoted securities and units issued by InvITs and REITs shall be valued in accordance with the existing instructions for quoted securities. For unquoted InvIT and REIT units, valuation shall be based on the NAV disclosed by the respective trust.

(Link: RBI Circular 268/2026 Dated 22/09/2026)

Amendments to RBI Payments Banks Classification, Valuation, and Operation of Investment Portfolio Directions: The amendments provide clarity and uniform practices for valuation of units of Infrastructure Investment Trusts (InvITs) and Real Estate Investment Trusts (REITs). It prescribes that quoted securities and units issued by InvITs and REITs shall be valued in accordance with the existing instructions for quoted securities. For unquoted InvIT and REIT units, valuation shall be based on the NAV disclosed by the respective trust.

(Link: RBI Circular 267/2026 Dated 22/09/2026)

Amendments to RBI Small Finance Banks Classification, Valuation, and Operation of Investment Portfolio Directions: The amendments provide clarity and uniform practices for valuation of units of Infrastructure Investment Trusts (InvITs) and Real Estate Investment Trusts (REITs). It prescribes that quoted securities and units issued by InvITs and REITs shall be valued in accordance with the existing instructions for quoted securities. For unquoted InvIT and REIT units, valuation shall be based on the NAV disclosed by the respective trust.

(Link: RBI Circular 266/2026 Dated 22/09/2026)

Amendments to RBI Local Area Banks Classification, Valuation, and Operation of Investment Portfolio Directions: The amendments provide clarity and uniform practices for valuation of units of Infrastructure Investment Trusts (InvITs) and Real Estate Investment Trusts (REITs). It prescribes that quoted securities and units issued by InvITs and REITs shall be valued in accordance with the existing instructions for quoted securities. For unquoted InvIT and REIT units, valuation shall be based on the NAV disclosed by the respective trust.

(Link: RBI Circular 265/2026 Dated 22/09/2026)

Amendments to RBI Commercial Banks Classification, Valuation, and Operation of Investment Portfolio Directions: The amendments provide clarity and uniform practices for valuation of units of Infrastructure Investment Trusts (InvITs) and Real Estate Investment Trusts (REITs). It prescribes that quoted securities and units issued by InvITs and REITs shall be valued in accordance with the existing instructions for quoted securities. For unquoted InvIT and REIT units, valuation shall be based on the NAV disclosed by the respective trust.

(Link: RBI Circular 264/2026 Dated 22/09/2026)

Novation Rules for OTC Derivative Contracts: RBI has finalised instructions relating to novation of over-the-counter (OTC) derivative contracts. RBI has incorporated the novation requirements into the respective Directions governing OTC foreign exchange, rupee interest rate, government securities and credit derivative contracts.

Novation’ means the replacement of a market maker with another market maker in an OTC derivative contract between two counterparties (transferor, who steps out of the existing deal, and remaining party) to an OTC derivative transaction with a new contract between remaining party and a third party (transferee). The transferee becomes the new counterparty to the remaining party.

(Link: RBI Circular 263/2026 Dated 22/09/2026)

J. Miscellaneous

SC, Arbitration Initiated Without Consent held Non Est (void) in Law: Case of Arth Micro Finance Private Ltd vs Shivalik Small Finance Bank Ltd, SC Judgement Dated 19^th September 2026. The apex court ruled that an arbitral tribunal appointed without proven mutual consent or in the face of valid bias objections is non est (void) in law.

SC, Highest Bid cannot Cure Tender Disqualification: Case of Micky Traders Vs LRY Labour Contractor, SC Judgement Dated 13^th August 2026. The party offered the highest bid but it lacked the requisite two years of specialized experience. The apex court held that a higher financial bid cannot cure a bidder failure to meet mandatory tender eligibility and experience requirements.

*******

Compiled by:- CMA Yash Paul Bhola, MBA, FCMA. Former Director (Finance), National Fertilizers Limited.

Disclaimer: The contents of this article are for informational purposes only. The user may refer to the relevant notification/ circular/ decisions issued by the respective authorities for specific interpretation and compliances related to a particular subject matter)